2007 Revisions to FDR and DPR regarding Cheese. Framework for Inspection. October 30, 2008 Dairy Stakeholder Meeting. Aussi disponible en français

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1 2007 Revisions to FDR and DPR regarding Cheese Framework for Inspection October 30, 2008 Dairy Stakeholder Meeting Aussi disponible en français 2007 Her Majesty the Queen in Right of Canada (Canadian Food Inspection Agency), all rights reserved. Use without permission is prohibited.

2 Purpose of Meeting 1. To provide background information regarding the implementation approach for the revised cheese compositional standards in the Food and Drug Regulations and Dairy Products Regulations. 2. To build awareness of the formula to be used to assess compliance. 2

3 Background Revisions to the Food and Drug Regulations (FDR) and the Dairy Products Regulations (DPR) harmonize and clarify the ingredients permitted for cheese making. The DPR also introduces cheese import licensing. The revisions come into effect December 14, The revisions require that cheese derive a minimum amount of its casein from fluid milks and ultrafiltered milks rather than from other milk products AND have a whey protein to casein ratio that does not exceed that of milk. The casein content derived from milks must meet or exceed the percentages of the total protein content of the cheese, dependent on the variety total protein refers to the value determined using internationally recognized official methods which measure total nitrogen (Kjeldhal) 3

4 Inspection Framework Compliance Objectives Industry must meet regulatory requirements and be able to demonstrate that products are in compliance Assess compliance through review and verification of documentation Focus verification efforts based on priority and risk Scope Cheese - imported and domestic (produced by federally registered establishments) Foods (imported and domestic) declaring cheese as an ingredient (e.g. lasagna, pizza) 4

5 FDR/DPR Cheese Compositional Standards Framework 5 If concerns or issues arise CFIA Monitoring No monitoring Non-Compliance Non-Compliance

6 Cheese Importers All cheese importers will require a CFIA cheese import licence as of December 14, 2008 An Application for a Cheese Import Licence form completed and required documentation attached (recall program, cheese list, and if required, establishment plans, sanitation and pest control programs, water analysis, etc.) During regular monitoring of the Importer Verification activity which assesses Good Importing Practices (GIP), CFIA will assess compliance of imported cheese, including the revised compositional requirements. Acceptable documentation includes: Cheese specification sheets indicating specific ingredients Supporting documentation 6

7 Federally Registered Dairy Establishments CFIA will perform a verification activity to assess compliance of cheese to the compositional standards based on the establishment s current and available records: Same frequency as other consumer protection activities Random selection of cheese variety and several vat records over a one month period Corresponding lab reports/invoices related to milk payment for protein analysis results Supporting documentation (e.g. lab analysis) for protein declaration on Nutrition Facts Table Random sampling and analysis of cheese for total protein by CFIA 7

8 Imported and Domestic Prepared Foods Inspection approaches for imported and domestic prepared foods (non-registered) are different from the registered food commodities. CFIA conducts priority based inspections and responds to complaints for the non-registered sector. CFIA will respond to complaints related to foods that contain cheese to determine compliance to the regulations. The regulated party will be expected to show appropriate documentation to demonstrate compliance 8

9 Enforcement Approach Instances of non-compliance could result in one or more of the following enforcement actions: Letters of Non-Compliance; Seizure and Detention of Product; Suspension/Cancellation of Registration; Suspension/Cancellation of Licence; or Prosecution. Each instance will be assessed on a case-by-case basis and the action(s) taken will be proportionate to the gravity of the non-compliance. 9

10 Methods to Validate Compliance 1. CFIA will randomly assess whether the cheese whey protein to casein ratio requirement (Codex parameter) is met by reviewing vat records and performing analytical testing of the cheese, if required. 2. Casein derived from milks must meet regulatory standards Although there is no analytical methodology related to casein origin in the final product, this requirement can be assessed by applying the following formula: % Casein derived from milks = Quantity of milks X Protein of milks X Casein number X Retention coefficient Protein content of cheese X Quantity of cheese % CDM = Q m x P m x CN x RC P c x Q c 10

11 Data sources for formula Quantity of milks - individual ingredient quantities: vat records Protein of milks - milk payment lab reports/invoices Casein number - for milks, use constant values Retention coefficient - use constant value Protein content of cheese plant and/or CFIA lab analysis Quantity of Cheese total vat quantity: vat records 11

12 Constant Values Although milk composition can vary depending on time of year, breed, and feed, the following constant values will be used to facilitate more standardized cheese formulations and to enable uniform implementation: Retention coefficient - constant value: 0.96 (Van Slyke Casein number: equation for cheese yield) for milk: constant value: (AAFC research) for cream: (xx% BF): x (P x %BF)/P considering 2mg MFGM protein is associated to each g fat. (MFGM = milk fat globule membrane) for UF milk: value is estimated from protein concentration (P): CN = (P ) x 0.813)/P. 1 Couture, L. and Britten, M Variation saisonnières des propriétés physico-chimiques du lait. Dossier recherche 1.2,Cellule de recherche en physico-chimie du lait, St-Hyacinthe (Qc.), 10pp. 12

13 Next Steps Distribution of Information Letter to regulated parties to explain the framework for inspection CFIA training of inspection staff to assess compliance 13

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